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US/UK Tax and Wealth Planning

Our clients with business interests and personal wealth in the US and the UK are required to navigate two complex and very different tax systems. Successful wealth planning for such clients requires the lead advisor to be "ambidextrous" in that they understand the tax treatment of a proposed transaction in both countries simultaneously. This is what makes Mishcon de Reya different. We have a team of specialist UK and US tax and trust lawyers advising on US tax and trust concepts, enabling us to provide integrated solutions.

We enable our clients to comply with their UK and US tax reporting and payment obligations while maximising available tax reliefs, and advise on all areas of personal tax and trust and estate planning including on the formation, administration, taxation and governance of tax and wealth planning structures.

We travel to the US regularly, coordinating and working closely with our clients' advisors there, including US tax advisors, bankers and family offices.

Key Areas of Expertise

We advise UK resident US settlors and/or beneficiaries of US trusts on managing their potential exposure to double taxation. We also have experience of mitigating the risk of double taxation on income from US LLCs and S Corps.

We regularly advise on the use of excluded property trusts and protected settlements for UK resident, US citizens as well as on the use and creation of life insurance trusts for US citizens who are living in the UK.

We also advise on the US federal tax implications of trust structures with a non-US component, including:

  • Foreign grantor trust planning;
  • Use of trusts to hold US-sited investments;
  • Trust structuring for US settlors (for both US federal tax and succession planning purposes).

Family Limited Partnerships can be especially important for US citizens where UK inheritance tax considerations preclude the use of trusts.

We assist US citizens with their pre-UK immigration tax planning.

We regularly provide US federal income tax advice in relation to relocating to the US.  We advise on the most beneficial US visa categories for immigration and tax purposes, providing comprehensive application support, and overcoming ineligibilities and refusals.

We deal with all aspects of inheritance tax planning but have particular expertise in advising US based British expats on managing their potential UK inheritance tax exposure.

We advise UK resident US citizens on their ability to use the EU Succession Regulation to exercise their rights to avoid “forced heirship” rules on European  assets.

We have the expertise to draft trusts that simultaneously qualify as foreign grantor trusts for US purposes and protected trusts for UK income tax purposes.

We can assist with the establishing of dual-qualified charitable entities.

We regularly draft estate plans, integrated Wills and revocable trusts for US/UK citizens and have extensive experience in cross border estate administration and probate.  We regularly assist US lawyers to apply for UK Grants of Probate.

We advise on the US federal tax implications on the passing of a non-US settlor (post grantor planning).

We help you navigate the tax implications of relinquishing US residency/Green Card status or citizenship.  Facilitating the immigration process, including preparation for exit interviews, the in-person oath, and assistance with all necessary documentation.

We regularly advise on addressing historic US federal tax non-compliance.  Advising individuals, trust companies, and fiduciaries in relation to US persons' reporting obligations in relation to non-US entities and non-US trust structures.

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